NC0083275_Staff Comments_20160519

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Berry, Ron
From:
Belnick, Tom
Sent: Thursday, May 19, 2016 11:38 AM
To: Berry, Ron
Subject: FW: Stream Classification Question
Ron- please print and put copy in NPDES Permit File. Thanks.
Tom Belnick
Supervisor
NPDES Complex Permitting Unit, DWR
North Carolina Department of Environmental Quality
919-807-6390 office
[e-mail]
512 North Salisbury Street
1617 Mail Service Center
Raleigh, NC 27669
g —�'--Nothing Compares
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Allocco, Marcia
Sent: Thursday, May 19, 201610:09 AM
To: Berry, Ron <[e-mail]>; Kountis, Elizabeth <[e-mail]>
Cc: Belnick, Tom <[e-mail]>; Gore, Deborah <[e-mail]>
Subject: RE: Stream Classification Question
0
Ron - thanks for the follow-up! I'll touch base with the Town of Forest City and make sure they review their draft
permit more closely to ensure the change to the receiving stream classification was made. As of our Monday
meeting the Town noted they wanted to continue ownership of the Harris WWTP even if the new textile company
purchases the facility since their long-term plan is to expand a nearby industrial park and tie that flow into this
WWTP. Since there is no domestic going to the plant under this scenario I would think this would affect their
discharge permit limits; textile plant would be only source of wastewater (I believe). Discussions on Monday noted
that another facility in Forest City would be purchased that is tied to the Town of Forest City (through
pretreatment) and it would take 60% of the 2.6 MGD maximum and the Harris W WTP would get 40% of the 2.6
MGD maximum. The manufacturer is looking for 1,000,000 sf of space and right now that can only be

accomplished through the purchase of two separate facilities and an expansion of the facility tied to the Harris
WWTP. Of course all things are subject to change but this one is moving quickly.
Regards,
Marcia
From: Berry, Ron
Sent: Wednesday, May 18, 2016 9:09 AM
To: Kountis, Elizabeth <[e-mail]>; Allocco, Marcia <[e-mail]>
Cc: Belnick, Tom <[e-mail]>
Subject: RE: Stream Classification Question
The reclassification from C to WS-IV was not known when developing the NPDES renewal permit NC0083275 that is
currently active. However, the limits and requirements in the current active NPDES permit are the same that would
apply to a WS-IV reclassification for this existing discharge. After further review, the discharge location listed in the fact
sheet as Index 9-(36.5) is an error. The correct Index is 9-(25.5). 1 will follow up and be sure BIMS is corrected to show
WS-IV and 9-(25.5).
Ron Berry
Engineer
Division of Water Resources/Complex Permitting
North Carolina Department of Environmental Quality
919 807 6396 office
ron.berrvt7a ncdenr.00v
512 N. Salisbury Street
1617 Mail Service Center
Raleigh, NC 27699-1617
c Nothing Compares..`
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Kountis, Elizabeth
Sent: Tuesday, May 17, 2016 3:42 PM
To: Allocco, Marcia <[e-mail]>
Cc: Berry, Ron <[e-mail]>
Subject: RE: Stream Classification Question

I have learned ALWAYS to confirm what is in BIMS or any other internet/shapefile source with other info sources, so glad
you are doing so. Please always feel free to contact me as a info source on classification issues, too.
To answer your last question in your email below, yes, a reclassification was done after 2002. A WS-IV reclassification
became effective 3/1/2007 for the Town of Forest City for an intake on a Class C classified section of the Broad River.
However, (9-22) was not involved nor was 9-(36.5); you are wondering why I bring up 9-(36.5) but you will see why
below. 9-(25.5) and 9-(34.5) were the 2 sections of the Broad River involved in the 2007 reclassification (see below).
If you look at
https://deg.nc.gov/river-basin-classification-schedule
and click on the hydrologic list for the Broad River, you will see the following:
• BROAD RIVER from Carolina Mountain Power Company to Rutherford County SR 1167 _ effective
08/O1/98 =
• BROAD RIVER From a point 0.2 mile downstream of Rutherford County SR 1145 to a point 0.5 mile upstream of
the Town of Forest City proposed water supply intake ® 03/01/07 _
• BROAD RIVER From a point 0.5 mile upstream of the Town of Forest City proposed water supply intake to Town
of Forest City proposed water supply intake _ 03/01/07 _
• BROAD RIVER From Town of Forest City proposed water supply intake to a point approximately 0.3 mile
downstream of Cane Creek' 08/03/92 _
I'd also look at
http://ncdenr.maps.arcgis.com/a pps/weba ppviewer/index. htm I? id=6el25ad7628f494694e259c80dd64265
and you can turn on the Water Supply Watershed layer and DWR NPDES Wastewater layers. If you do, it says
NC0083275 discharges to 9-(25.5) Broad River, which is clasisfied as WS-IV. Here's the screen shot witht the section of
the river highlighted and another screen shot with the red triangle showing the discharge.

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NPDES Wastewater Facilit
Facility
Harris Plant W%
Name:
Permittee:
Town of Forest
Permit NO.:
NCO083275
Permit Type:
Industrial Proc(
Commercial W:
Discharge
Major/Minor:
Minor
i
Type of
Govemment -
OWner:
County:
Rutherford
Permitted
910,000
Flow:
Permit
Expired
' Stahw•
Zoom to
6

Berry, Ron
From: Berry, Ron
Sent: Wednesday, May 18, 2016 12:08 PM
To: Hintz, Randy
Cc: Heim, Tim
Subject: Recent Corrections to Harris Plant WWTP NCO083275
Attachments: 201605181151.pdf
Mr. Hintz,
In a recent review of the current active Harris Plant (Forest City) WWTP NPDES permit NCO083275 issued in 2014 it was
noted the stream classification did not state the correct classification WS-IV (this receiving stream segment was
reclassified from C to WS-IV in 2007). Consequently, as required for a discharge to WS-IV a 2014 renewal draft permit
was not send to your attention for review and comment. The current active NPDES permit requirements were
reviewed and found to be consistent with WS-IV permitting requirements, thus, no changes to the existing permit
requirements are necessary. Attached is a marked copy of the corrected NPDES permit. We are updating information in
our files and BIMS to reflect the correct stream classification.
The NPDES permit's fact sheet also incorrectly listed the stream Index number for the receiving stream. Again, we are
updating our files and BIMS to list the correct Index number.
If you have any questions let me know.
Ron Berry
Engineer
Division of Water Resources/Complex Permitting
North Carolina Department of Environmental Quality
919 807 6396 office
[e-mail]
512 N. Salisbury Street
1617 Mail Service Center
Raleigh, NC 27699-1617
-"Nothing Compares
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

Permit NC0083275
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER RESOURCES
PERMIT.
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended, the
Town of Forest City
is hereby authorized to discharge wastewater from a facility located at the
Harris Plant WWTP
1843 Jack McKinney Road south of Rutherfordton
Rutherford County
to receiving waters designated as the Broad River in the Broad River Basin in accordance with effluent
limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV hereof.
This permit shall become effective ...................................... January 1, 2015.
This permit and authorization to discharge shall expire at midnight on ....... December 31, 2019.
Signed this day ........... November 24, 2014.
oK)s,,4AL oi4-Af;o ${ fiC/t C3FdNt� Fo°� pt/1F_Clv✓L
Thomas A. Reeder, Director
Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 7

Permit NCO083275
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
Town of Forest City
is hereby authorized to:
Upon approval of an Authorization to Construct and after submittal of the signed
Engineering Certificate, to operate a 0.91 MGD wastewater treatment plant that consist of the
following components:
➢ Three (3) influent bar screens
➢ One (1) 0.25 MG neutralization basin with mixers
➢ Two (2) 1.5 MG aeration basins with recycle pumps and blowers
➢ Two (2) 12 ft diameter clarifiers with RAS pumps
➢ Effluent flow meter
➢ One (1) cascade post aeration basin
➢ Effluent composite sampler
➢ Seven (7) 0.5 MG sludge digestors
➢ One (1) solids dewatering centrifuge
➢ One (1) 1.0 MG sludge holding tank
➢ Disinfection system (Future)
➢ Stand by generator (Future)
➢ Influent composite sampler (Future)
➢ Grit Removal System (Future)
This facility is located at 1843 Jack McKinney Road south of Rutherfordton at the Harris Plant
W WTP in Rutherford County.
2. Discharge wastewater from said treatment works at the location specified on the attached map into
the Broad River, classified Class -&waters in the Broad River Basin.
WS-1Qggo 6-4 —If
Page 2 of 7

Permit NCO083275
Part I
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
a. During the period beginning on the effective date of this permit and upon approval of an Authorization to
Construct, and after submittal of the signed Engineering Certificate, and lasting until expiration, the Permittee
is authorized to discharge from Outfall 001. Such discharges shall be limited and monitored I by the
Permittee as specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING
REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
-Frequency
Sample
Tye
Sample.
Location
Flow
0.91 MGD
Continuous
Recording
Influent or
Effluent
BOD, 5-day, 20°C 2
18.4 mg/L
27.6 mg/L
3/Week
Composite
Influent and
Effluent
Total Suspended Solids 2
30.0 mg/L
45.0 mg/L
3/Week
Composite
Influent and
Effluent
Fecal Coliform
(geometric mean)
200/100
ml
400/100
ml
3/Week
Grab
Effluent
pH
Not less than 6.0 S.U. nor greater
than 9.0 S.U.
3/Week
Grab
Effluent
Total Residual Chlorine 3
28 µg/L
3/Week
Grab
Effluent
Temperature, °C
3/Week
Grab
Effluent
Total Nitrogen (TN), mg/L 4
Semi-annually
Composite
Effluent
Total Phosphorus, mg/L .
Semi-annually
Composite
Effluent
Chronic Toxicity 5
1
Quarterly -
Composite
Effluent
Footnotes:
1. No later than 270 days from the effective date of this permit, begin submitting discharge monitoring
reports electronically using NC D"'s eDMR application system. See Special Condition A.(5).
2. The monthly average effluent Total Suspended Solids and BOD concentrations shall not exceed 15 %
of the respective influent value (85 % removal).
3. If chlorine or chlorine derivatives are used for disinfection then the facility must monitor total residual
chlorine and meet the compliance limit. The Division shall consider all effluent TRC values reported
below 50 µg/L to be in compliance with the permit. However, the Permittee shall continue to record and
submit all values reported by a North Carolina certified laboratory (including field certified), even if
these values fall below 50 µg/L. 1
4. TN = TKN + NO3-N + NO2-N, where TN is Total Nitrogen, TKN is Total Kjeldahl Nitrogen, and NO3-
N + NO2-N are Nitrate and Nitrite Nitrogen respectively.
5. Chronic Toxicity (Ceriodaphnia dubia) P/F at 0.75%: March, June, September, and December. See
Special Condition A. (2).
b. There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 3 of 7

Permit NCO083275
A. (2) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 0.75%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in
the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised December 2010, or
subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised- December 2010) or subsequent versions. The tests will be performed during the months of
March, June, September, and December. These months signify the first month of each three month
toxicity testing quarter assigned to the facility. Effluent sampling for this testing must be obtained
during representative effluent discharge and shall be performed at the NPDES permitted final effluent
discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV
below the permit limit, then multiple -concentration testing shall be performed at a minimum, in
each of the two following months as described in "North Carolina Phase II Chronic Whole
Effluent Toxicity Test Procedure" (Revised -December 2010) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the parameter
code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWR Form AT-
3 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if
chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during anionth in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test
form indicating the facility name, permit number, pipe number, county, and the month/year of the report
with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the
Environmental Sciences Section at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring
will be required during the following month. Assessment of toxicity compliance is based on the toxicity
testing quarter, which is the three month time interval that begins on the first day of the month in which
toxicity testing is required by this permit and continues until the final day of the third month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division
of Water Resources indicate potential impacts to the receiving stream, this permit may be re -opened and
modified to include alternate monitoring requirements or limits.
Page 4 of 7

Permit NCO083275
(Continued A. (2) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY))
If the Permittee monitors any pollutant more frequently than required by this permit, the results of such
monitoring shall be included in the calculation and reporting of the data submitted on the DMR and AT
Forms.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival, minimum control organism reproduction, and appropriate environmental controls,
shall constitute an invalid test and will require immediate follow-up testing to be completed no later
than the last day of the month following the month of the initial monitoring.
A. (3) NOTIFICATION OF PROPOSED CHANGE IN WASTEWATER
CHARCTERISTICS
The Permittee shall notify the Division prior to commencing a discharge of industrial wastewater. The
current permit reflects a discharge of 100% domestic wastewater. Any significant changes in wastewater
characteristics will require a Major Permit Modification.
A. (4) EFFLUENT MERCURY ANALYSIS
The Permittee shall provide in conjunction with the next permit renewal application a minimum of one
effluent mercury analysis using EPA Method 1631 E determined within 12 months prior to the
application date. Any additional effluent mercury measurements conducted shall also be submitted with
the renewal application.
If the mercury analysis is not provided with the application, the application may be returned as
incomplete and the Permittee considered non -compliant.
A. (5) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
Proposed federal regulations require electronic submittal of all discharge monitoring reports (DMRs)
and specify that, if a state does not establish a system to receive such submittals, then permittees must
submit DMRs electronically to the Environmental Protection Agency (EPA). The Division anticipates
that these regulations will be adopted and is beginning implementation in late 2013.
NOTE: This special condition supplements or supersedes the following sections within Part II of this
permit (Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.)
• Section D. (6.)
• Section E. (5.)
Reporting
Records Retention
Monitoring Reports
1. Reporting [Supersedes Section D. (2.) and Section E. (5.) (a)1
Beginning no later than 270 days from the effective date of this permit, the permittee shall begin
reporting discharge monitoring data electronically using the NC DWR's Electronic Discharge
Monitoring Report (eDMR) internet application.
Page 5 of 7

Permit NCO083275
(Continued A. (5) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS)
Monitoring results obtained during the previous month(s) shall be summarized for each month and
submitted electronically using eDMR. The eDMR system allows permitted facilities to enter
monitoring data and submit DMRs electronically using the internet. Until such time that the state's
eDMR application is compliant with EPA's Cross -Media Electronic Reporting Regulation
(CROMERR), permittees will be required to submit all discharge monitoring data to the state
electronically using eDMR and will be required to complete the eDMR submission by printing,
signing, and submitting one signed original and a copy of the computer printed eDMR to the
following address:
NC DENR / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility
being physically located in an area where less than 10 percent of the households have broadband
access, then a temporary waiver from the NPDES electronic reporting requirements may be granted
and discharge monitoring data may be submitted on paper DMR forms (MR 1, J. 1, 2, 3) or
alternative forms approved by the Director. Duplicate signed copies shall be submitted to the
mailing address above.
Requests for temporary waivers from the NPDES electronic reporting requirements must be
submitted in writing to the Division for written approval at least sixty (60) days prior to the date the
facility would be required under this permit to begin using eDMR. Temporary waivers shall be valid
for twelve (12) months and shall thereupon expire. At such time, DMRs shall be submitted
electronically to the Division unless the permittee re -applies for and is granted a new temporary
waiver by the Division.
Information on eDMR and application for a temporary waiver from the NPDES electronic reporting
requirements is found on the following web page:
http://portal.ncdenr.org/web/wq/adminibog/ipu/edmr
Regardless of the submission method, the first DMR is due on the last day of the month following
the issuance of the permit or in the case of a new facility, on the last day of the month following the
commencement of discharge.
2. Signatory Requirements [Supplements Section B. (11.) (b) and supersedes Section B. (11.) Ml
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II,
Section B. (11.)(a) or by a duly authorized representative of that person as described in Part II,
Section B. (I 1.)(b). A person, and not a position, must be delegated signatory authority for eDMR
reporting purposes.
Page 6of7

Permit NCO083275
(Continued A. (5) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS)
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user
account and login credentials to access the eDMR system. For more information on North
Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account, please visit
the following web page:
http://portal.ncdenr.org/web/wq/admin/bog/ipu/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make
the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION
WILL BE ACCEPTED:
"I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the information,
the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I
am aware that there are significant penalties for submitting false information, including the
possibility of fines and imprisonment for knowing violations. "
3. Records Retention [Supplements Section D. (6.)]
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR
submissions. These records or copies shall be maintained for a period of at least 3 years from the
date of the report. This period may be extended by request of the Director at any time [40 CFR
122.41].
Page 7 of 7

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USGS Quad: G11NW Fingerville East
Outfall Facili
Latitude: 35' 12' 23" N 350 12' 21" N
Longitude: 81' 53' 15" W 810 53' 4" W
Stream Class: W S-t\1 vCV6
Subbasin:03-08-02 HUC:03050105
Stream: Broad River
North Facility Location
Harris Plant WWTPNCO083275
Rutherford County

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Berry, Ron
From: Berry, Ron
Sent: Wednesday, May 18, 2016 9:14 AM
To: Weaver, Charles
Subject: FW: Stream Classification Question
Charles,
For the current active permit NCO083275 in BIMS the receiving stream classification needs to be corrected to WS-IV and
the stream Index corrected to 9-(25.5).
Thanks
From: Berry, Ron
Sent: Wednesday, May 18, 2016 9:09 AM
To: Kountis, Elizabeth <[e-mail]>; Allocco, Marcia <[e-mail]>
Cc: Belnick, Tom <[e-mail]>
Subject: RE: Stream Classification Question
The reclassification from C to WS-IV was not known when developing the NPDES renewal permit NCO083275 that is
currently active. However, the limits and requirements in the current active NPDES permit are the same that would
apply to a WS-IV reclassification for this existing discharge. After further review, the discharge location listed in the fact
sheet as Index 9-(36.5) is an error. The correct Index is 9-(25.5). 1 will follow up and be sure BIMS is corrected to show
WS-IV and 9-(25.5).
Ron Berry
Engineer
Division of Water Resources/Complex Permitting
North Carolina Department of Environmental Quality
919 807 6396 office
ron.berrvCa ncdenr.gov
512 N. Salisbury Street
1617 Mail Service Center
Raleigh, NC 27699-1617
'Nothing Compares --
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Kountis, Elizabeth
Sent: Tuesday, May 17, 2016 3:42 PM